PRIVACY POLICY

This policy is addressed to users of the website flowaysystem.com. The Policy describes the principles of collecting and using the data of Website users that are collected directly from them or via cookies and similar technologies.

Data controller.

The data controller of personal data of the Website users is the Polish company SEVEN DOTS limited liability company with its registered office in Warsaw (00-728) at Bobrowiecka street no. 1, with the KRS number: 0000341932, NIP (tax identification number): 5213547535, REGON (statistical identification number): 142112097, e-mail: office@flowaysystem.com. In matters related to the processing of your data by the Data controller, you can use the above contact details.

Who is the Policy for?

People using the Website, including people using the online contact form.

Data source.

1. If you contacted the Data controller, the data was provided to us directly from you.
2. If your data has been provided in connection with a matter handled by the person who referred the matter to the Data controller, the source of the data is that person. In this case, the Data controller receives identification, address and case-related data, such as a description of the case.

The scope of collected data.

1. The Website allows you to contact the Data controller and provide him with your identification, contact and content-related data. In connection with the above, we process personal data of common categories, such as: name and surname, telephone number, IP, e-mail address and/or company name, possibly also other data that you will provide via the Website..
2. The Data controller collects data on the user’s device in order to ensure the most optimal operation of the Website, such as the computer’s IP address, information contained in cookies and other similar technologies, session data, internet browser data, device data, data on activity on the Website, including on individual subpages.
3. The Data controller may collect geolocation data only if the user has consented to the Data controller’s access to geolocation. Geolocation information is used to provide you with more customized product and service offers.
4. The data indicated in points 2 and 3 do not contain data on the identity of users, but, in combination with other information, may constitute personal data and therefore the Data controller covers them with full protection in accordance with the provisions of the GDPR.

Purpose and legal basis for the processing of personal data.

Your data may be processed for the purpose:

• for network traffic analysis, ensuring security on the Website and adapting the content to the needs of users based on the legitimate interest of the Data controller (Article 6 (1) (f) of the GDPR); in connection with the consent to the use of certain cookies or other similar technologies, expressed by the appropriate settings of the web browser in connection with the consent to geolocation (Article 6 (1) (a) of the GDPR);
• for answering questions, forwarding the ordered offer and conducting correspondence in order to settle the matter, based on your consent and the legitimate interest of the Data controller, which is the fulfillment of users’ requests (Article 6 (1) (a) and (f) of the GDPR).

The Data controller may post marketing information about its products or services on the Website. Displaying this content is made by the Data controller in accordance with art. 6 (1) (f) GDPR, in accordance with the Data controller’s legitimate interest in the publication of content related to the services provided and promotional campaigns in which the Data controller is involved. At the same time, this action does not violate the rights and freedoms of users, users expect to receive similar content, and sometimes even expect it or it is their direct purpose of visiting the Website.

Right to withdraw consent.

You may withdraw your consent to the processing of contact data at any time by contacting the Data controller. Withdrawal of consent may make it difficult or impossible to contact you. At the same time, the withdrawal of consent does not affect the lawfulness of the processing which was carried out on the basis of consent before its withdrawal.

Obligation or voluntary data submission.

1. Providing data by you for purposes related to handling the case is voluntary, but necessary. Failure to provide them may hinder or prevent the consideration of the case.
2. Providing the data necessary for the static analysis of the Website users is voluntary. You can use the so-called “incognito mode” in order to browse the website without providing the Data controller with information about your visit to the Website. Using “the incognito mode”, and therefore failure to provide data, does not affect the possibility of using the Website.

The rights resulting from the GDPR in the scope of processed data.

You have the right:

• to request the Data controller to inspect your data, as well as receive a copy of them (Article 15 of the GDPR);
• to request the Data controller to rectify or correct the data (Article 16 of the GDPR) – in relation to the request for rectification of data, if you notice that the data is incorrect or incomplete;
• to request the Data controller to delete data (Article 17 of the GDPR);
• to request the Data controller to limit processing (Article 18 of the GDPR) – e.g. when you notice that the data is incorrect – you may request that the processing of your data be restricted for a period that allows us to check the correctness of this data.

In order to exercise your rights, please contact the Data controller in writing, by e-mail or by phone.

You have also the right to lodge a complaint in relation to the processing of your personal data by the Data controller directly to the supervisory authority – the President of the Office for Personal Data Protection in Warsaw.

The recipients of your personal data.

The Data controller discloses the personal data of users only to processing entities under the concluded contracts for entrusting the processing of personal data in order to provide services to the Data controller, e.g. hosting and operating the Website, IT services, marketing and PR services, legal and advisory services.

Data retention period.

Your personal data will be stored until the consent is withdrawn or the matter is settled, and then until the expiry of the limitation period for the parties’ claims related to its implementation.

Data related to network traffic analysis collected via cookies and similar technologies may be stored until the cookie expires. Some cookies never expire, therefore the data storage time will be equivalent to the time necessary for the Data controller to achieve the goals related to data collection, such as ensuring security and analyzing historical data related to traffic on the Website.

Data transfer to a third country or an international organization.

The data is transferred to third countries (i.e. countries outside the European Union or the European Economic Area) only when it is necessary for the performance of an obligation or results from legal provisions or if you have given your consent.

We transfer your personal data to service providers and companies that are part of the group outside the European Economic Area, i.e. to Switzerland and the USA.

We conclude appropriate agreements with all service providers required under the provisions of the law on the protection of personal data.

The use of cookies and similar technologies.

The website enables the collection of information about the user via cookies and similar technologies, the use of which most often involves the installation of this tool on the user’s device (computer, smartphone, etc.). This information is used to remember the user’s decisions (choosing the font, contrast, accepting the policy), maintaining the user’s session (e.g. after logging in), remembering the password (with consent), collecting information about the user’s device and his/her visit to ensure security, but also visit analysis and content customization.

Information obtained through cookies and similar technologies is not combined with other data of the Website users, nor is it used for their identification by the Data controller.

The user can set the browser to block certain types of cookies and other technologies, by specifying, for example, that only those that are necessary for the correct display of the page will be allowed. By default, most browsers allow the use of all cookies, but the user has the option to change these settings at any time, and can also delete already installed cookies. Each browser allows such operation through one of the options available in the settings or preferences.

The user also has the option of using the Website in the so-called “incognito mode”, which blocks the possibility of collecting data about his visit.

The Website uses the following cookies:

• Strictly necessary cookies

These cookies are necessary for the functioning of the Website and cannot be turned off in the systems. You can set your browser to block or warn you about these cookies, but some parts of the Website will then not work. These cookies do not store any personal information.

• Functional cookies

These cookies enable the Website to provide more functionality and personalization for the Website user. If the user does not allow the use of these cookies, some or all services related to the Website may not function properly.

• Analytical cookies

These cookies allow the Data controller to count visits and traffic sources, thanks to which he can measure and improve the performance of the Website. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you visited our Website.

By default, only the necessary cookies are enabled, which allow the Website to function properly. The inclusion of other files (analytical, functional) depends on your decision. Below you can accept all files or refuse to use them (except necessary ones).

We use the cookies we collect in:

• Google Analytics – uses cookie technology to enable the Website to analyze traffic sources and the manner in which visitors use it.
• Google Ads – uses cookie technology to enable the Website to assess the correctness and effectiveness of its advertising activities using the AdWords network.

The data used as part of these solutions are always anonymous data.

Social media plugins.

To make the Website more user-friendly, we have included social media plugins on the Website. Social media plugins are web tabs that allow Website users to access our profile through various providers::

• Facebook, where we have a profile: Facebook
• YouTube, where we have a profile:Youtube
• LinkedIn, where we have a profile: LinkedIn
• Twitter, where we have a profile: Twitter
• Reddit, where we have a profile: Reddit

By clicking on the icons (plugins) of social media, the user is directed to the Data controller’s profile maintained by a given provider, i.e. information about the user is transferred only after the first click and is directed to the given provider.

In connection with your visits to our profiles in social media, we process your personal data.

In addition to us (i.e. independently of us), the social media provider is also responsible for the processing of your personal data. Information on the processing of your personal data when using the services of a given provider can be found in the privacy policy of the respective provider.

When you click the “Like” or “Follow” icon on our profile, post comments on our posts or send us direct messages via social media, the Data controller processes your personal data.

The Data controller processes your data only for the necessary answers to questions, commenting on entries and communication with users as part of our business and the content provided by us. Your activity related to the use of these profiles will not be archived by us outside the given social media.

Your personal data that we process in connection with running our fan pages include:

• ID in a given social medium (usually name and surname),
• basic identification data and other data published by you on your profile on a given social media, profile picture (if you have published it),
• other photos (which may also present an image) you voluntarily publish under our profile posts,
• the content of your comments and the content of the conversation conducted, for example, via the Messenger application,
• anonymous statistical data on people visiting the fanpage (in the case of Facebook, they are available using the “Facebook Insights” function provided by Facebook in accordance with the non-changeable conditions of using Facebook, collected thanks to cookies, each of which contains a unique user code that can be linked to the connection data of users registered on Facebook, which is downloaded and processed when the profile is opened).

We process your personal data in order to inform you about our activity via our profiles on social networks, promote various events that we organize, promote our brand and products, build and maintain a community associated with us and to communicate through the available functionalities offered by the social networking sites. The indicated actions constitute our legitimate interest in accordance with art. 6 sec. 1 lit. f) GDPR. The processing of your personal data also serves to pursue a legitimate interest in the form of conducting analyzes regarding the functioning, popularity, and method of using our profile. The processing of personal data also takes place on the basis of Art. 6 sec. 1 lit. b) GDPR in connection with taking action at your request before concluding the contract, if you ask us about our products.

In the case of social media profiles, the recipients of your data are the owners of individual social media on the non-changeable data rules specified by the relevant social network. In addition, we entrust personal data to entities supporting the running of our profiles in social media, as well as other entities supporting our activities, as well as entities authorized to receive personal data on the basis of legal provisions.

Your data will be processed for the period necessary to achieve the above-mentioned processing purposes, i.e.:

• the information we have in private messages will be stored for no longer than 6 months from answering your questions or until the end and limitation of claims under the contract, if such has been concluded with you;
• in the case of information that we have as part of the comments you have provided, it will be available until the author deletes it;
• your personal data collected by a given social media, i.e. the history of entries, history of activity in the Messenger application, history on the YouTube portal, are subject to the storage rules specified in the regulations of these sites;
• for data processed on the basis of the legitimate interest of the Data controller will be processed until the objection is effectively filed or the interest ceases to exist;
• statistical data on people visiting the fanpage available through the “Facebook Insights” function will be processed for the duration of the availability of this data on Facebook, which is 2 years.

Providing your personal data is voluntary, but necessary to view your profile, post comments or send messages via a social media.

We will delete your personal data, if they are no longer needed for the above-mentioned processing purposes, and there is no legal obligation to store them to prevent their deletion. You have the right at any time to access your personal data free of charge, transfer, correct and, where applicable, delete it, as well as the right to object to the processing of your data that is processed by us, or to withdraw your consent to the processing of personal data with effect for the future.

Changes to the Privacy Policy.

The policy may be supplemented or updated in accordance with the current needs of the Data controller in order to provide users with up-to-date and reliable information about their personal data and information about them. Users will be informed about any changes to the Privacy Policy on the Website.

The last update of the Privacy Policy: 20 December 2022